Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries
Articles Posted in Criminal Law
Aamer, et al. v. Obama, et al.
Petitioners, detainees who have been cleared for release but remain held at Guantanamo Bay, engaged in a hunger strike unless and until they were released. The government subsequently instituted a force-feeding protocol. Petitioners invoked the district court's habeas jurisdiction and moved for a preliminary injunction prohibiting the authorities from force-feeding them. Two district courts denied petitioners' request, concluding that the Military Commissions Act (MCA), Pub. L. No. 109-366, 120 Stat. 2600, stripped federal courts of jurisdiction to consider such challenges brought by Guantanamo detainees. The court concluded that, under the law of this circuit, petitioners' challenges to the conditions of their confinement properly sounded in habeas corpus and were not barred by the MCA. The court concluded, however, that petitioners failed to establish their entitlement to preliminary injunctive relief. Accordingly, the court affirmed the district courts' denials of petitioners' applications for a preliminary injunction. View "Aamer, et al. v. Obama, et al." on Justia Law
United States v. Wyche
In 2008, Defendants Wyche and Smith moved for sentence reductions after amendments to the United States Sentencing Guidelines lowered the sentencing ranges for cocaine base crimes. The district court granted Smith's motion but did not then rule on Wyche's motion. In 2011, Wyche and Smith filed resentencing motions after the Sentencing Commission again lowered the sentencing ranges for cocaine base offenses. The district court denied Smith's most recent resentencing motion and both of Wyche's motions. Because Wyche's pre-2011 amendment total offense level was 41, his total offense level and guideline range under the 2011 amendment would in fact increase, thereby precluding relief under 18 U.S.C. 3582(c)(2). Because the record reflected that the 2012 district court's calculation of 8.4 kilograms was not clearly erroneous, a quantity finding greater than 840 grams of cocaine base was not clearly erroneous either. And because Smith was not eligible for a second sentence reduction, the 2012 district court did not abuse its discretion in denying his motion. Accordingly, the court affirmed the district court's judgments. View "United States v. Wyche" on Justia Law
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Criminal Law, U.S. D.C. Circuit Court of Appeals
Roane, et al. v. Tandy, et al.
Appellant, a federal death row inmate, moved to intervene in this lawsuit, which challenged the government's method of carrying out lethal injections and its failure to disclose its execution procedures. The district court denied the motion. As a preliminary matter, the court concluded that the this suit still presents a live controversy and was, therefore, not moot. The court also concluded that appellant's intervention was timely. Accordingly, the court reversed and remanded, directing the district court to grant appellant's motion to intervene as of right where granting the intervention was highly unlikely to disadvantage the existing parties. View "Roane, et al. v. Tandy, et al." on Justia Law
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Criminal Law, U.S. D.C. Circuit Court of Appeals
Janko v. Gates, et al.
Appellant was detained at Guantanamo Bay for seven years as an enemy combatant. After the Supreme Court decided that Guantanamo detainees have a constitutional right to challenge the basis of their detentions in Boumediene v. Bush, the district court granted appellant's petition for a writ of habeas corpus. The United States released appellant and he filed a complaint a year later, seeking to recover injuries sustained during his detention. At issue was whether the district court has jurisdiction over appellant's claims. The court held that 28 U.S.C. 2241(e)(2) barred claims brought on behalf of aliens determined by Combatant Status Review Tribunals (CSRTs) to have been properly detained. The court also concluded that the application of section 2241(e)(2) to appellant was constitutional. Accordingly, the court affirmed the dismissal of appellant's claims because Congress has denied the district court jurisdiction to entertain his claims under section 2241(e)(2). View "Janko v. Gates, et al." on Justia Law
United States v. Thomas
Defendants appealed their convictions stemming from a narcotics distribution scheme in Washington D.C. Defendants and six others were indicted, and the district court conducted two trials. The court held that defendants' evidentiary challenges and their contention regarding the submission of unplayed and unredacted phone calls failed to demonstrate that reversal of their convictions was warranted; such errors as occurred were harmless for lack of substantial prejudice; the district court's responses to jury notes impermissibly interfered with the jury's independent role as the finder of fact and the court vacated the convictions on the tainted counts; the government conceded that the district court erred in imposing Defendant Thomas' sentences of life imprisonment in violation of Apprendi v. New Jersey and the court vacated his life sentences for narcotics conspiracy and RICO conspiracy; and the court remanded the case for resentencing and otherwise affirmed the judgments of conviction. View "United States v. Thomas" on Justia Law
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Criminal Law, U.S. D.C. Circuit Court of Appeals
United States v. Eiland
Defendants, convicted of various narcotics-related offenses, alleged that numerous errors affected their second trial. Defendants were involved in an extensive drug ring and the government indicted twenty-one defendants in total, subsequently separating defendants for trial in two groups. The court rejected most of defendants' arguments; vacated Defendant Miller's insufficiently supported conviction for his participation in a continuing criminal enterprise and remanded for resentencing; and vacated the fine imposed on Defendant Eiland by the district court and remanded for reconsideration of that portion of Eiland's sentence. View "United States v. Eiland" on Justia Law
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Criminal Law, U.S. D.C. Circuit Court of Appeals
United States v. Dillon
This appeal challenged the district court's order authorizing the Government to medicate defendant by force if necessary for the sole purpose of rendering him competent to stand trial. In Sell v. United States, the Supreme Court held that the Government may, on "rare" occasions, forcibly medicate a defendant to restore his competency. The court found no merit in defendant's claim that the district court committed reversible error in failing to consider the prospect that he might face civil confinement; even if defendant was correct that he was not dangerous apart from allegedly threatening the President of the United States with bodily harm, this fact by itself would not render unimportant the Government's interest in prosecuting him for a serious and dangerous crime; and the district court's factual findings have a sound evidentiary basis and were not clearly erroneous. Accordingly, the court affirmed the district court's order authorizing involuntary medication. View "United States v. Dillon" on Justia Law
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Criminal Law, U.S. D.C. Circuit Court of Appeals
Maqaleh, et al. v. Panetta, et al.
In these three appeals, enemy combatants held by the United States at Bagram Airfield Military Base in northwest Afghanistan sought access to the writ of habeas corpus. Over three years ago, the court concluded that enemy combatants held at Bagram could not invoke the Suspension Clause to challenge their detentions. In these appeals, the court dismissed the petitions for want of jurisdiction where, because the Suspension Clause did not run to Bagram, section 7 of the 2006 Military Commissions Act, Pub. L. No. 109-366, 120 Stat. 2600, did not effect any unconstitutional suspension of the writ. The court remanded Hamidullah's petition to the district court for the limited purpose of determining whether he is in the sole custody of the government of Pakistan. View "Maqaleh, et al. v. Panetta, et al." on Justia Law
United States v. Pole
Defendant appealed his convictions for five counts of wire fraud and one count of theft. Defendant, while serving as former Senator Edward M. Kennedy's office manager, awarded himself unauthorized bonuses. The court rejected defendant's evidentiary arguments; remanded his colorable ineffective assistance claims; and vacated and remanded the restitution order because neither the jury nor the district court made factual findings sufficient to support the order. View "United States v. Pole" on Justia Law
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Criminal Law, U.S. D.C. Circuit Court of Appeals
United States v. McKinney
Appellant challenged the district court's finding that he was not suffering from a severe mental illness when he represented himself at trial nearly six years ago. The court concluded, consistent with Indiana v. Edwards, that it had no reason to disturb the district court's fine-tuned judgment that appellant did not suffer from severe mental illness to the point where he was not competent to conduct trial proceedings by himself. Accordingly, the court affirmed the judgment of the district court. View "United States v. McKinney" on Justia Law
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Criminal Law, U.S. D.C. Circuit Court of Appeals